Oakland’s Vegetation Management Plan – Our Comment (Deadline 11 June 2018)

June 7, 2018

Oakland’s Vegetation Management Plan is to cut down thousands of trees and use toxic pesticides to prevent resprouting. If you wish to comment, the deadline is June 11, 2018. Send your email to VMPcomments@oaklandvegmanagement.org

We’ve published a brief comment here (see below).

Here’s our comment:

The San Francisco Forest Alliance is a non-profit (501 (c)4) organization that was created in 2012 to advocate for the preservation of our urban forest and eliminate the use of pesticides in our public parks. Our mission is Inclusive Environmentalism.

We are familiar with the strategy of justifying the destruction of non-native trees based on the claim that they are more flammable than native trees, because it has been used in San Francisco – although there is no history of and little risk of wildfire here.

Oakland’s Draft Vegetation Management Plan appears to be using the same rationale for destroying healthy trees and using pesticides to prevent them from resprouting. We are therefore writing to request that the draft be revised to limit all tree destruction to the creation of defensible space around structures, as defined by California law. We also request that Oakland not use pesticides to implement its vegetation management plan.

At a time of climate change, destroying healthy trees is irresponsible. Climate change is a global environmental issue that effects everyone, including the residents of San Francisco. Therefore, we ask that unnecessary tree removals be avoided.

Likewise, the use of pesticides in our watershed is an unnecessary health hazard that affects all residents around the San Francisco Bay, including wildlife.

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Why a NO vote on AB 2470 (June 2018 election)

May 24, 2018

AB 2470, “Invasive Species” is a bill to “establish the Invasive Species Council of California, composed as prescribed, to help coordinate a comprehensive effort to exclude invasive species already established in the state. The bill would establish a California Invasive Species Advisory Committee to advise the council on a broad array of issues related to preventing the introduction of invasive species and providing for their control or eradication, as well as minimizing the economic, ecological, and human health impacts that invasive species cause…”

Fortunately, the Bill has been amended so no funds are being allocated to this effort. We still think it’s a dangerous bill that will result in a massive increase in pesticide use and environmental destruction.

LETTER FROM SAN FRANCISCO FOREST ALLIANCE

Here’s our letter on the subject:

——————-

Our members attended a recent budget town hall conducted by Assembly Member Phil Ting. It sharpened our appreciation of California’s needs in the fields of housing, education and health care.

With many thanks for removing funding for Weed Management Areas and Invasive Species Fund from AB 2470, we question the necessity of establishing both an Invasive Species Council of California and a California Invasive Species Advisory Committee proposed in the Bill.

When councils/committees are established – the requests for funding will follow.
We have observed that the current California Invasive Plant Council (Cal IPC) is an organization dedicated to eliminating plants which they deem undesirable, by the use of highly hazardous herbicides. We find this unacceptable.

Spraying of calla lilies here, in San Francisco, with a high hazard herbicide is but one example of these damaging practices. While calla lilies don’t endanger the health of the residents, there is plenty of evidence that the chemicals used to kill these lilies do. Just last year the Cal IPC added over 50 “potentially invasive” plants to the list of those where they claim herbicide spraying is justified.

Some of the plants designated as “undesirable” are “non-native” trees, many of which have been here for over 100 years and had long since became naturalized and habitats for insects, birds and animals both “native” and “non-native.”

Tree removals cause array of problems.

According to Scientific American: “from logging, agricultural production and other economic activities, deforestation adds more atmospheric CO2 than the sum total of cars and trucks on the world’s roads.” “Native” restorations/removal of “undesirable” trees are activities destroying forests, although they present themselves as environmental endeavors.
When trees are felled they release the carbon they are storing into the atmosphere, the future carbon sequestration is lost, so is the air pollution reduction. There are issues of potential landslides in hilly areas, increase in wind and noise, loss of wildlife habitat.

And, of course, the stumps of killed trees are treated with high hazard herbicides.

According to the Bill, the Invasive Species Council of California and the California Invasive Species Advisory Committee would be established “to help coordinate a comprehensive effort to exclude invasive species already established in the state…” We contend that the means of such “exclusions” are far more damaging and cause far more severe economic, ecological and human health impacts than the “invasive” species possibly can.

We urge the NO vote on AB 2470.

Thank you,

San Francisco Forest Alliance

We have been disturbed by the tendency in the established environmental movement to villainize “non-native” “invasive” species as a basis for declaring a “war” on them. It provides an opportunity to raise or deploy funding, to use a great deal of pesticides, and to “take action” by cutting down trees and tearing out habitat – even when it is environmentally destructive. We oppose the establishment of further institutions that will have a vested interest in these activities.

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Oyster Bay: Firehose of Funds means a Firehose of Herbicides

May 9, 2018

This article is reprinted from the website Death of a Million Trees with permission and minor changes.

 

OYSTER BAY: A FIREHOSE OF PUBLIC FUNDING SUPPLIES A FIREHOSE OF HERBICIDES

Oyster Bay is one of several East Bay Regional Parks along the east side of the bay that is a former garbage dump built on landfill. We visited Oyster Bay for the first time in 2011 after a former Deputy General Manager of the park district told us that it is a “beautiful native plant garden” and a model for a similar project at Albany Bulb, another former garbage dump being “restored” by the park district.

When we visited seven years ago, we found a park in the early stages of being destroyed in order to rebuild it as a native plant museum. Since there were never any native plants on this landfill, we can’t call it a “restoration.” We took many pictures of the park in 2011 that are available HERE.

We recently decided it was time to revisit the park when we noticed pictures of it in the recently published annual report of the park district’s Integrated Pest Management program, indicating recent changes in the development of the park. My article today is about what is happening now at Oyster Bay. It is still not a “beautiful native plant garden.”

“RESTORING” GRASSLAND  

Non-native annual grassland. Oyster Bay April 2011

Seven years ago, most of Oyster Bay was acres of non-native annual grasses. Since then, most of those acres of grassland have been plowed up and are in various stages of being planted with (one species?) of native bunch grass (purple needle grass?).

Stages of grassland conversion. Oyster Bay May 2018

On our May 1st visit, there were at least 8 pesticide application notices posted where the native bunch grass has been planted. Several different herbicides will be used in those sprayings: glyphosate, Garlon (triclopyr), and Milestone (aminopyralid).

Herbicide Application Notices, Oyster Bay May 2018

Grassland “restoration” in California is notoriously difficult. Million Trees has published several articles about futile attempts to convert non-native annual grassland to native grassland:

We wish EBRPD good luck in this effort to convert acres of non-native annual grass into native bunch grass. Frankly, it looks like a lot of public money down the drain to us. It also looks like an excuse to use a lot of herbicide.

Redwing blackbird in non-native mustard. Oyster Bay May 2018

Who benefits from this project? Not the taxpayer. Not the park visitor who is now exposed to a lot of herbicide that wasn’t required in the past. Not the wildlife, birds, and insects that lived in and ate the non-native vegetation. (We spotted a coyote running through the stumps of bunch grass. Was he/she looking for cover?)

DESTROYING TREES AND REPLACING THEM 

Pittosporum forest was an excellent visual screen, sound barrier, and wind break. It was healthy and well-suited to the conditions on this site. It was probably home to many animals.
Oyster Bay April 2011

When we visited Oyster Bay in 2011, many trees had already been destroyed, but there was still a dense forest of non-native pittosporum. That forest is gone and the park district has planted one small area with native trees as a “visual screen” of the Waste Management Facility next door. We identified these native trees and shrubs: ironwood (native to the Channel Islands), coast live oak, buckeye, toyon, juniper, mallow, holly leaf cherry, and redbud.

Native trees planted at Oyster Bay, May 2018

Ground around trees is green with dye used when herbicide is sprayed. Oyster Bay, May 2018

We also saw a notice of herbicide application near the trees. The ground around the trees was covered in green dye, which is added to herbicide when it is sprayed so that the applicator can tell what is done. There were men dressed in white hazard suits, driving park district trucks, apparently getting ready to continue the application of herbicides.

Will the trees survive this poisoning of the soil all around them? There are many examples of trees being killed by spraying herbicides under them. Herbicides are often mobile in the soil. Herbicides damage the soil by killing beneficial microbes and mycorrhizal fungi that facilitate the movement of water and nutrients from the soil to the tree roots.

Herbicide sprayed around newly planted trees. Oyster Bay May 2018

NOT A FUN DAY AT THE PARK

It wasn’t a fun day at the park and it isn’t fun to write about it. I decided to tell you about this visit after reading the most recent edition of the Journal of the California Native Plant Society, Fremontia (Vol. 46 No. 1). The introductory article of this “Special Issue on Urban Wildlands” is illustrated with a photo of Oyster Bay. I nearly choked on this statement in that article: “In order to control invasive plants, agencies and volunteers have sometimes resorted to using herbicides as a step in integrated pest control. While use of herbicides is contentious, the use for spot treatments has enabled small groups of volunteers to successfully eliminate invasive weeds in some areas where future herbicide use will not be needed.”

That is a PATENTLY FALSE statement. The California Invasive Plant Council conducted a survey of land managers in 2014. Ninety-four percent of land managers reported using herbicides to control plants they consider “invasive.” Sixty-two percent reported using herbicides frequently. The park district’s most recent IPM report for 2017 corroborates the use of herbicides to eradicate plants they consider “invasive.” The park district report also makes it clear that they have been spraying herbicide for a very long time. For example, they have been spraying non-native spartina marsh grass (in the bay and along creeks) with imazapyr for 15 years!

Attempting to eradicate non-native plants is NOT a short-term project. It is a forever commitment to using herbicides…LOTS of herbicide. To claim otherwise is to mislead, unless you are completely ignorant of what is actually being done.

YOU ARE PAYING FOR THIS

Another reason why I am publishing this article is to inform you that you are paying for these projects. The park district recently published a list of 492 active park improvement projects in 2018 (scroll down to page 71), many of which are native plant “restorations.” The majority of them are being paid for with grants of public money from federal, State, and local agencies as well as a few parcel taxes. Taxpayers had the opportunity to vote for the parcel taxes. They will have the opportunity to vote for new sources of funding for these projects:

  • Proposition 68 will provide $4.1 BILLION dollars for “park and water” improvements. It will be on your ballot on June 5, 2018. Roughly a third of the money will be allocated for “protection of natural habitats.” (1) Although the project at Oyster Bay does not look “natural” to us, that’s how the park district and other public agencies categorize these projects that (attempt to) convert non-native vegetation to native vegetation.
  • Measure CC renewal will be on the ballot in Alameda and Contra Costa counties on November 6, 2018. The park district has made a commitment to allocate 40% of the available funding to “natural resource projects.” Although the anticipated revenue (about $50 million) seems small, it is used as leverage to apply for big State grants, which require cost-sharing funding. Measure CC is essentially seed money for the much bigger federal and State funding sources.

I would like to vote for both of these measures because our parks are very important to me. If voting for these measures would actually improve the parks, I would do so. But that’s not what I see happening in our parks. What I see is a lot of damage: tree stumps, piles of wood chips, dead vegetation killed by herbicides, herbicide application notices, signs telling me not to step on fragile plants, etc.

Stay out of Oyster Bay to avoid unnecessary exposure to herbicides and keep your dogs out of Oyster Bay for the same reason. Unfortunately wildlife doesn’t have that option. They live there. Oyster Bay, May 2018

  1. “States big bond for little projects,” SF Chronicle, May 5, 2018

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Roundup: Probably Carcinogenic, and What Else?

March 13, 2018

It’s now widely known that Roundup has been found to be a probable carcinogen by the World Health Organization. (We wrote about that here: WHO – Roundup Probably Carcinogenic).

This is particularly disturbing, because it’s a very widely-used pesticide and the amounts found in humans have increased 5x since 1994 according to a UCSD study. Not only is it used in agriculture, it’s (still) used in our parks. Marin County has prohibited its use on public properties, but San Francisco’s Department of the Environment only reclassified it from Tier II (More Hazardous) to Tier I (Most Hazardous). The Natural Resources Department (NRD) of San Francisco Recreation and Parks Dept (SFRPD) continues to use it.

Photo of warning sign. Garlon, Aquamaster, Milestone on Mt Davidson. March 2018

Garlon, Aquamaster, Milestone on Mt Davidson. March 2018

But it’s not just a probable carcinogen. Research indicates a bunch of other issues:

VERY LIKELY AN ENDOCRINE DISRUPTOR

It’s very likely to also be an endocrine disrupter, which means it acts like a hormone in the human body, and can be a problem at very low doses.

Hormone disruption diagram - Source: NIH

Hormone disruption – Source: NIH

In a letter an EPA scientist Dr Marion Copley sent before she died, she not only said it was carcinogenic, she noted “glyphosate was originally designed as a chelating agent…” and lists the issues with chelating agents, including, “Chelaters are endocrine disrupters…” (That article is here: “It is essentially certain that glyphosate causes cancer.”)

If you want to read about how endocrine disruptors work, that’s a link to the National Institutes of Health website. It notes: “Research shows that endocrine disruptors may pose the greatest risk during prenatal and early postnatal development when organ and neural systems are forming.”

BIRTH DEFECTS IN VERTEBRATES

A paper published May 2010 in the journal, Chemical Research in Toxicology linked glyphosate to birth defects in vertebrates. We’d like people who have assumed that Roundup’s problems come mainly from its surfactant POEA to take a look. (This is not to say POEA is harmless. That has been implicated in embryonic cell death also, in a 2008 French study published in the same journal.)

In Argentina, glyphosate (the active ingredient of Roundup) is widely used on soybean. In soybean-growing areas, there were reports of increased birth defects of a particular type: malformed heads, eyes, and brains. A groups of researchers therefore decided to investigate whether glyphosate could indeed cause that type of birth defect.

The abstract of the article indicates that Roundup increased retinoic acid activity in vertebrate embryos, causing “neural defects and craniofacial malformations.”

Heart-breaking Birth Defects

Women of child-bearing age should be especially careful. The most vulnerable period, according to the paper, is in the first 2-8 weeks of pregnancy. Many people don’t even know they’re pregnant that early on. Furthermore, even the mature placenta is permeable to glyphosate. After 2.5 hours of perfusion, 15% of it crosses over.

The actual article, which we read elsewhere describes some of the birth defects: microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead, like the picture here); and neural tube defects. These are quite devastating. Many fetuses do not come to term, and many babies with these conditions die within hours or days.

INTERFERING WITH REPRODUCTION

There’s some evidence that glyphosate interferes with male reproduction, too. A 2014 article published in Science in Society in the UK, entitled “Glyphosate/ Roundup and Human Male Infertility” links glyphosate to falling sperm counts and lowered testosterone levels.

National Institutes of Health published a  paper in August 2000 that indicated Roundup interfered with reproductive hormones in rats.

DISRUPTION OF GUT BACTERIA

Other research has implicated glyphosate in other risk factors, particularly since it can disrupt gut bacteria in humans. We wrote about that here: Pesticides and Cancer, Glyphosate and Gut Bugs.

A 2013 article at RodalesOrganicLife.com suggests the growing evidence against glyphosate, possibly the world’s most widely used herbicide: ‘Once called “safer than aspirin,” glyphosate’s reputation for safety isn’t holding up to the scrutiny of independent research. More and more non-industry-funded scientists are finding links between the chemical and all sorts of problems, including cell death, birth defects, miscarriage, low sperm counts, DNA damage, and more recently, destruction of gut bacteria.’

Researchers found that glyphosate residues on food interfere with certain enzymes, with the result that  “…glyphosate enhances the damaging effects of other food borne chemical residues and environmental toxins. Negative impact on the body is insidious and manifests slowly over time as inflammation damages cellular systems throughout the body.”

[That paper, published in 2013 the journal Entropy, is HERE.]
It suggests that glyphosate might be causing a lot of the health problems that have been associated with Western diets – including “obesity, diabetes, heart disease, depression, autism, infertility, cancer and Alzheimer’s disease.”

BAD FOR THE ENVIRONMENT AND MOST LIVING THINGS

Glyphosate is bad for most living things. Research by way of a review of literature published in December 2017 by Springer Publishing concluded:

“Glyphosate poses serious threat to multicellular organisms as well. Its toxicological effects have been traced from lower invertebrates to higher vertebrates. Effects have been observed in annelids (earthworms), arthropods (crustaceans and insects), mollusks, echinoderms, fish, reptiles, amphibians and birds.”

It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

It damages the soil. How? It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil. Research also indicates it kills beneficial soil fungi while allowing dangerous ones to grow.  There’s a good article about that on the Million Trees website: Gyphosate (AKA Roundup) is damaging the soil  that discusses a New York Times article on the subject.

WHO’S USING GLYPHOSATE?

Most of SFRPD has continued to decrease use of glyphosate in 2017 – except for the Natural Resource Department (NRD, formerly Natural Areas Program – NAP). Here’s the comparison.

These graphs are in fluid ounces of active ingredient. The blue section is the use in 2016, and the orange section shows 2017.  NRD actually used slightly less glyphosate in 2016 than the rest of SFRPD (excluding Harding Golf Course, which is managed under an outside PGA contract). But in 2017, it used nearly 2 1/2 times as much.

Bear in mind that NRD accounts for a quarter of our park land in San Francisco.

Though we are glad SFRPD has been reducing use, we should be wary: Why Low Dose Pesticides are Still Hazards. Endocrine disruptors can act at very low dilutions, and in their case, the old adage that the “dose makes the poison” is not true.

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San Francisco “Natural Resources” Herbicide Usage Up 57% in 2017

March 6, 2018

We have recently analyzed the data for herbicide use in the full year 2017 for San Francisco’s so-called “Natural Resources Department” (NRD – formerly Natural Areas Program). It’s up 57% from the previous year.

NRD is a department of San Francisco Recreation and Parks Department (SFRPD). We were greatly encouraged when NRD started reducing herbicide use in 2014. Before that, pesticide use had increased sharply from 2009 onwards. (You can read an article about that here: SF’s Natural Areas Program – more pesticide in 2013.) Another sharp reduction in 2016 was even more encouraging – though it’s never come down to 2008 or 2009 levels. (The graph above shows annual NRD herbicide usage in fluid ounces of active ingredient.)

But this year, it’s up again, almost to 2015 levels. We have been hoping that SFRPD is working to eliminate all Tier I and Tier II herbicides, with leadership from the Department of the Environment (SF Environment).

For the rest of SFRPD (excluding Harding Golf Course, which is managed under a PGA contract), they have actually reduced usage. They use a greater variety of herbicides than NRD, of which more later. But they are using less – across all their parks and golf courses – than the NRD is. NRD forms a quarter of the area of SFRPD.

WHAT’S WRONG WITH THESE HERBICIDES?

NRD uses four herbicides: Two that SF Environment classifies as Tier I (“Most Hazardous”) and two classified as Tier II (“More Hazardous”). The Tier I herbicides are Roundup/ Aquamaster (glyphosate) and Garlon 4 Ultra (triclopyr); and Stalker/ Polaris/ Habitat (imazapyr) and Milestone VM (Aminopyralid) are Tier II. (In the first picture, with the white dog, the sign posted on Mount Davidson indicates they are using Aquamaster, Garlon, and Milestone in March 2018.)

These hazard rankings can change: Roundup/ Aquamaster (glyphosate) was reclassified from Tier II to Tier I when the World Health Organization found it was a probable human carcinogen. Milestone (Aminopyralid) was reclassified from Tier I to Tier II, despite the fact that it is extremely persistent and mobile in the environment.

THE FEARSOME FOUR

As you research these herbicides, you may find – as we did – that much of the research originates with the companies that produce them. It may be unbiased, but the evidence is that it often is not. So we looked for other sources, which are easier to find for well-established herbicides like glyphosate (Roundup or Aquamaster). It doesn’t mean the others are innocuous.

ROUNDUP or AQUAMASTER (Glyphosate)

  • Carcinogenic. In April 2015, the World Health Organization determined glyphosate was a “probably carcinogenic.”  EPA scientist Dr Marion Copley  sent a letter before her death saying it was essentially certain that glyphosate  causes cancer. She also said that as a chelater, it was likely an endocrine disruptor.
  • Associated with birth defects. It’s been associated with birth-defects, especially around the head, brain and neural tube — defects like microcephaly (tiny head); microphthalmia (tiny undeveloped eyes); impairment of hindbrain development; cyclopia (also called cyclocephaly – a single eye in the middle of the forehead).
  • Bad for the soil. Research indicates it kills beneficial soil fungi while allowing dangerous ones to grow.
    It binds to the soil, and acts as a “chelating agent” – trapping elements like magnesium that plants need to grow and thus impoverishing the soil.
  • Bad for other living things. It’s very dangerous to frogs and other amphibians, and quite dangerous to fish.

GARLON (Triclopyr)

  • Garlon is even more hazardous than Roundup. It’s been classified as Tier I for at least as as long as we have been monitoring pesticide use in San Francisco.
  • Garlon “causes severe birth defects in rats at relatively low levels of exposure.” Baby rats were born with brains outside their skulls, or no eyelids. Exposed adult females rats also had more failed pregnancies.
  • Rat and dog studies showed damage to the kidneys, the liver, and the blood.
  • About 1-2% of Garlon falling on human skin is absorbed within a day. For rodents, its absorbed twelve times as fast. It’s unclear what happens to predators such as hawks that eat the affected rodents.
  • Dogs  may be particularly vulnerable; their kidneys may not be able to handle Garlon as well as rats or humans.  Dow Chemical objected when the Environmental Protection agency noted decreased red-dye excretion as an adverse effect, so now it’s just listed as an “effect.”
  • It very probably alters soil biology. “Garlon 4 can inhibit growth in the mycorrhizal fungi…” ( soil funguses that help plant nutrition.)
  • It’s particularly dangerous to aquatic creatures: fish (particularly salmon); invertebrates; and aquatic plants.
  • Garlon can persist for up to two years in dead vegetation .

The NRD uses Garlon extensively against oxalis. If it terminated its war on oxalis, it could stop using Garlon altogether.

POLARIS, HABITAT, STALKER  (Imazapyr)
This is a relatively new pesticide, and not much is known about it — except that it’s very persistent. In Sweden, it was found in the soil 8 years after a single application. It not only doesn’t degrade, some plants excrete it through their roots so it travels through the environment.

It can cause irreversible damage to the eyes, and irritate the skin and mucosa. As early as 1996, the Journal of Pesticide Reform noted that a major breakdown product  is quinolic acid, which is “irritating to eyes, the respiratory system and skin. It is also a neurotoxin, causing nerve lesions and symptoms similar to Huntington’s disease.”
It’s prohibited in the European Union countries, since 2002; and in Norway since December 2001 because of groundwater concerns.

MILESTONE (Aminopyralid)
Milestone is a Dow product that kills broadleaf plants while ignoring most grasses. This is even more problematically persistent than Imazapyr; a computer search yielded warnings of poisoned compost.

What?

It seems that this chemical is so persistent that if it’s sprayed on plants, and animals eat those plants, it still doesn’t break down. They excrete the stuff in their droppings. If those are composted — it still doesn’t break down the chemical. So now the compost’s got weedkiller in it, and it doesn’t nourish the plants fertilized with the compost, it kills them.

The manufacturer sees this as  a benefit. “Because of its residual activity, control can last all season long, or into the season after application on certain weed species,” says the Dow AgroSciences FAQ sheet.
Nevertheless, after an outcry and problems, Dow AgroSciences stopped selling Milestone in the UK for a number of years. It’s also prohibited for use in New York.

IT’S TIME TO STOP

There’s growing evidence that herbicides are more dangerous, more mobile, and more persistent than their manufacturers claim. Glyphosate, for instance, is widely found in all water sources, in the soil – and in people. A UCSF study of glyphosate in urine found: “Glyphosate residues were observed in 93% of urine samples in voluntary public testing in the U.S. general population; this is higher than the frequency observed in Europe using GC-MS (43.9%)”  and “exposure is likely due to dietary intake or environmental exposure.”

With endocrine disruptors, the old theory “the dose makes the poison” doesn’t work. They are potent at very low levels.

These are parks that we visit with our families, including kids and pets. Kids are particularly vulnerable to pesticides because of their low body weight and rapid growth. These are the watersheds that feed chemicals into our groundwater (which is also now being added to our domestic water supply).

The San Francisco Forest Alliance stands for No Pesticides in our Parks.

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Important Pesticide Meeting at City Hall, 20 Dec 2017

December 13, 2017

Toward the end of each year, SF Department of the Environment (SF Environment), which runs the Integrated Pest Management Program (IPM) holds an important public meeting. This year, it’s on December 20, 5-7 p.m. in Room 400 at San Francisco’s City Hall.

This meeting is to discuss three things, and take public comments and input: Changes to the approved list of pesticides for city use; the guidelines for pesticides use and public notification; and explaining the exemptions granted in 2017 to the rules.

Notice showing Pesticides to be used on blackberry on Mt Davidson, San Francisco - Nov 2017

Pesticides used on blackberry on Mt Davidson – Nov 2017

THREE THINGS ON THE PESTICIDE MEETING AGENDA

1. Changes to the approved list of pesticides for use on city properties. SF Environment publishes a list of pesticides that are okay to use on city-owned properties (our parks, lands owned by the Public Utilities Commission, Crystal Springs, the airport, Sharp Park and a few others). It divides these permitted pesticides into three tiers: Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous). This meeting discusses pesticides added, removed, or having their Tier classification changed.

The DRAFT for 2018 is here: b_draft_2018_reduced_risk_pesticide_list

2. Guidelines for pesticide use and public notification. Over the last year, IPM has been trying to develop guidelines for when and where these pesticides are prohibited; and also for how the public can be informed when pesticides are used. Here’s the current DRAFT of the guidelines: c_summary_of_major_changes_to_2017_restrictions_of_most-hazardous_herbicides

3. They also explain the exceptions they’ve granted in the previous year, i.e. 2017. They approved 21 exemptions in 2017. The list of exemptions is here: a_summary_of_pesticide_exemptions_for_2017

The one that particularly concerns us is permission to use Garlon 4 Ultra (probably the most toxic herbicide still permitted on City properties) on oxalis within fifteen feet of designated trails at Twin Peaks, Mount Davidson, McLaren Park, Bayview Hill and Corona Heights.

They argue: These parks have a diversity of native plants growing adjacent to trails including but not limited to: Grindelia hirsutula (gumplant), coast rock cress (Arabis blepharophylla), Pacific reed grass (Calamagrostis nutkaensis), stonecrop (Sedum spathulifolium), meadow white (Cerastium arvense), silver bush lupine (Lupinus albifrons), Mission bells (Fritilaria affinis), footsteps of spring (Sanicula arctopides), California buckwheat (Erigonium latifolium), soap plant (Chlorogalum pomeridianum), dichondra (Dichondra donelliana), varied lupine (Lupinus variicolor), California buttercup (Ranunculus californicus), checkerbloom (Sidalcea malvaeflora), campion flower (Silene scouleri) and coast red onion (Allium dichlamydeum). Many of these plants are considered sensitive species and some of them support important local wildlife, such as the lupine species that are host plants for the endangered Mission blue butterfly (Icaricia icariodes missionensis). SFRPD is obligated to manage the land at Twin Peaks for the Mission blue butterfly as part of the Recovery Plan with the U. S. Fish and Wildlife Service, including the management of oxalis. In recent years, Garlon 4 Ultra is being used to protect these sensitive areas from this invasive weed. The Oxalis pes-caprae is a major threat to the existing biodiversity of wildlife within the native grasslands. If left untreated these areas will greatly interfere with the progress already made in controlling this particular weed.

What it boils down to is the poorly-supported theory that oxalis will take over the world if they let it, an argument Nativist doyen Jake Sigg recently made in his newsletter while defending pesticide use. “Our most serious destroyer of biological diversity is the yellow oxalis, Oxalis pes-caprae. Because it is prolific, aggressive, and effectively practices chemical warfare, it is pushing out native species—the wildflowers that so delight us and which are needed as the base of the food chain for other creatures. Because it can’t be destroyed unless the bulb is killed, herbicides are mandatory.”

By contrast, actual research indicates oxalis is a poor competitor, and even the California Native Plant Society California Invasive Plant Council considers it only moderately invasive (mainly in sand dunes). [Edited to correct the organization reference.]

We understand that some opinions are influential even when opposing evidence surfaces, but in this case the tradeoff is the continued use of the most toxic herbicide that the city allows on its land. We’ve argued before that this tradeoff is not good for people, wildlife, or the environment. (See our presentation-format post: Garlon v. Oxalis in 10 Easy Slides ) We certainly do not wish it to be used near any trail where people go out with their kids and pets.

WE STAND FOR NO TOXIC PESTICIDES IN OUR PARKS

San Francisco Forest Alliance stands for an end to toxic pesticides in our parks. This can be done; the Marin Municipal Water District stopped using herbicides altogether some years ago. It means having a more practical approach to managing the landscape, and not declaring war on various species of plant.

However, we do have some concerns. Here are notes from Tom Borden, a public access advocate:

2017 exemptions
There is only one exemption from the posting requirements. It is for PUC right of ways. I understood pesticides were used at the GGP plant nursery without posting. Where is the exemption? I suspect herbicides are applied above the reservoir at 7th and Clarendon without posting. Where is the exemption for that?

Restrictions on Herbicides for City Properties
A2  Why are applications done by methods other than spray exempted from the requirement to use blue dye? If a stump has been daubed rather than sprayed, how will people know it’s not safe to sit on?

A2  Why say, “or in cases where posting is not otherwise required under the law”? Posting is always required by law, unless an exemption from posting is granted by IPM. Right now there is only one posting exemption on the IPM Exemptions log. If and when IPM issues another posting exemption, the land manager can also request an exemption from the blue marker dye requirement if there is a good reason to avoid the dye. Who does not want to use blue dye? Is it really expensive? Isn’t it beneficial to the people applying herbicides to be able to see what they already treated? Why shouldn’t people be able to see what was treated?

A7  Why can’t herbicides be used on green walls and green roofs? Whatever that logic is, why doesn’t it apply more broadly?

B9  Why don’t the protections for the public and employees extend to areas outside city limits? Do we only care about people in San Francisco?

B9  What is the relevance of public accessibility? The Chapter 3 of the San Francisco environment code protects City employees as well as the public. If “publicly inaccessible parcels” are to have lesser requirements for posting and demarcation, the law requires that the land manager apply for an exemption. As of today, there is only one posting exemption on file, for PUC rights of way. There should also be one for the GGP nursery. Other than that, we are not aware of any other “publicly inaccessible parcels” in the City. The general exception for “publicly inaccessible parcels” should be removed. It just introduces unnecessary ambiguity. If there is a genuinely publicly inaccessible parcel, and City employees can be protected, then IPM can issue an exception for that.

B9  Why are golf courses and areas managed for habitat conservation afforded less public protection? Don’t golfers, kids and hikers deserve protection too? Maybe the behavior of golfers is predictable, but people enjoying our wild parkland could be having a picnic, playing hide and seek, exploring, rolling down a hill, doing almost anything. There should be no exception to the demarcation requirements for “areas managed for habitat conservation”.

B12  If a trail exists, especially one not “actively maintained by City operations”, it is because people use it frequently. If the intent of these rules is to protect the public, all trails should be afforded the same protection. If the intent of these rules is to make life easy for land managers and punish people who use un-designated trails, you are on the right track.

B13  Please remove spray boom “definition” for broadcast spraying. The last part of the second sentence gets to the point, broadcast spraying means indiscriminately spraying all plants in an area, as opposed to targeting specific plants. In 2016 you saw video and photographic evidence that three men with backpack sprayers can perform broadcast spraying. Please use the definition for broadcast spraying that the rest of the world uses.

New thinking on Tier I
The new Restrictions do away with the idea that Tier I herbicides are only to be used when there is a critical need. Now Tier I can be used for anything except for prohibitions 10,11 & 12. The old restrictions limited where Tier I herbicides could be used based on a “need” that was balanced against the risks of use. Where has that gone? This seems like a real step backward.

Now land managers just need a reason that goes beyond cosmetics and they can apply Tier I herbicides anywhere as long as it is more than 15 feet from an area frequented by children and more than 15 feet from the land manager’s designated trails.

While we work toward the “No toxic pesticides in our parks” goal, we try to attend these meetings and believe that we have been able to work with SF Environment over the years to get some improvements.

  • SFRPD improved the signage for pesticide use, and is now encoding the use of colored dye to show where actual spraying has taken place.
  • More practical restrictions on pesticide use.
  • We’re encouraged by SF RPD’s reducing herbicide use in the last three years – excluding the Natural Areas (now the Natural Resources Division) and Harding Golf course, which is managed under contract by the PGA Tour. (The graphs below show pesticide usage by SFRPD ex NAP and Harding, and NAP/ NRD’s pesticide use. Please note that all measurements are in fluid ounces of active ingredient, but the scale on the two graphs are different.)

Filed under Applies Pesticides Tagged with , , , , ,

Pesticide Use in San Francisco Natural Areas Creeping Up Again – Oct 2017

November 20, 2017

We’ve received the pesticide usage reports for the first ten months of 2017, and we’re concerned. After reducing herbicide usage in the last four years, it’s creeping up again in the natural areas. The Natural Areas (now called the Natural Resources Department) has already used more herbicides (measured by active ingredient) than in all of 2016. It hasn’t reached 2015 levels, but park users hoped for further reduction, not an expansion in herbicide use.

San Francisco’s Department of the Environment runs the Integrated Pest Management (IPM) program for city-owned properties in San Francisco. It publishes an annual list of permissible pesticides, and classifies them into Tier III (Least Hazardous), Tier II (More Hazardous) and Tier I (Most Hazardous.)

The unnaturally-named Natural Resources division (NRD) of the San Francisco Recreation and Parks Department (SFRPD) used more Tier I  herbicides than the rest of SFRPD put together (excluding Harding Golf course, which is managed under a separate PGA contract – but including all the other city-owned golf courses). In fact, in the first ten months of 2017,  NRD used 69% of the Roundup and 100% of the Garlon used by SFRPD.

The parks mainly targeted thus far were:

  • Twin Peaks (sprayed 32 times);
  • Glen Canyon (sprayed 27 times);
  • McLaren Park (25 times);
  • Bayview Hill (14 times); and
  • Laguna Honda (PUC property – 13 times).

Other parks that got sprayed over five times in ten months were Mt Davidson (8 times); Marietta (a PUC property – 8 times); and Lake Merced, also 8 times.

NRD INCREASES USE OF CANCER-CAUSING ROUNDUP 

We especially noted that its usage of glyphosate (Roundup/ Aquamaster) has nearly doubled from 2016 (i.e., in ten months, NRD used nearly twice as much glyphosate as in the whole of 2016).

This is particularly worrisome since Roundup probably causes cancer. We wrote about that in these articles: World Health Organization: Roundup “Probably Carcinogenic” and in this report from an EPA scientist before she died reported on problems with pesticide assessments: “It is Essentially Certain that Glyphosate Causes Cancer”

This is the first time since the report came out we’ve seen an increase in its use.

GARLON IS WORSE

The other major Tier I pesticide being used is Garlon 4 Ultra (triclopyr). NRD is the only section of SFRPD that uses this chemical, which has been considered Most Hazardous and HIGH PRIORITY TO FIND ALTERNATIVE at least since 2009. It’s twenty times as harmful to women as to men. (Here’s our quick presentation on the subject: Garlon v. Oxalis in Ten Easy Slides.)

NRD uses this on oxalis, an early spring-flowering plant beloved of children, pollinators, and wildlife – and the general public, who enjoy its bright blooms as a sign of spring. It’s the only use of Garlon by NRD, and if they abandoned the vendetta against these Bermuda buttercups, they would not need to use this awful pesticide.

NEW WAR TARGETING CAPE MARIGOLD

Meanwhile, there’s a new city-wide war on a naturalized species: against arctotheca, or Cape Marigold. It’s another yellow-flowering plant that grows all over our city’s parks, and it’s on the list of 40 species (and counting) that the NRD wants to poison.  Here’s a picture from McLaren Park (together with Great Blue Heron that’s probably hunting gophers).

Cape Marigold occurs in both a fertile and an infertile form; both are considered only Moderately invasive by the California Invasive Plant Council – as is oxalis.

Unless NRD changes its approach and objectives to naturalized species of plants – and recognizes the need for inclusiveness in natural areas – there is little likelihood of eliminating pesticides from our parks. Aggressive management will inexorably result in increased herbicide use.

WHAT ABOUT THE REST OF SFRPD?

By contrast, the rest of SFRPD (excluding Harding Golf Course) seems to be on track to reduce usage again from 2016. For which kudos!

[Edited to Add: The graph below was corrected to indicate the last column shows usage only through Oct 2017, not the full year.]


The only department besides Natural Resources to regularly use pesticides is the Golden Gate Nursery. They wish to make sure the nursery stock they supply is pest-free before propagating it. This is less of a concern than NRD for several reasons: It’s not a public space, usage is confined in a small area and not on parks and hillsides where chemicals could spread to other areas.

We are concerned, though, that they are experimenting with several herbicides that were not earlier on SF Environment’s list: Axxe, Suppress, Clearcast and Finale. They are all considered Tier II, according to Dr Chris Geiger of SF Environment’s IPM.

Of these Axxe and Suppress seem to be less harmful. Suppress is considered acceptable for organic farming.

Clearcast is more concerning, as is Finale. You can see the Clearcast Label here: clearcast_Label.pdf 2016

Here’s the Finale Label: finale_msds

Both these pesticides have cautions regarding potential harm from immediate exposure. We will further research them, but more than the specifics, we’re concerned at the direction. Rather than working to eliminate herbicides from our parks, SFRPD seems to be looking for substitutes for Roundup. Thus far, these two chemicals have been used only in Nursery areas – the GGP Nursery, and the nursery at the Botanic Gardens.

SFRPD now has five Integrated Pest Management Specialists (compared to one before). This is good news to the extent that they will be working on mosquito abatement and alternatives to rat poisons. It’s bad news if it encourages SFRPD to open new battle fronts (like the war on Cape Marigold), or increase use of herbicides in the water, rather than changing its approach to eliminate pesticides in our parks. Here’s the note about their activities from an October meeting of SF Environment’s Policy Committee:  102317_attachment_c_-_agency_ipm_updates_for_2017

SF Forest Alliance reiterates our commitment to working toward No Toxic Pesticides in our parks. We recognize that it will be an uphill battle, as all current interests are in continuing pesticide use. Nevertheless, we believe that it is possible and is a worthwhile and environmentally-friendly goal for San Francisco.

 

 

Filed under "Natural" Areas Program, Applies Pesticides Tagged with , , , ,

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